IMSML Website Article 6/2023: Resolution MSC.525(106) - Amendments to the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers 2011 (2011 ESP Code), Part 1 of 4, Annex A, Part A

In the Malaysian Shipping Notice MSN 03/ 2023, issued by the Marine Department (MARDEP), Resolution MSC.525(106) was the sixth resolution of MSC 106 listed in Appendix I. It is one of the resolutions adopted by the 106th Session of the Maritime Safety Committee (MSC 106) of the International Maritime Organisation (IMO). These are the important points to note from the MARDEP summary. First, the resolution targets Parts A and B, of Annexes A and B respectively of the 2011 ESP Code. These amendments enhance the consistent implementation of survey requirements. Second, the main amendments include protective coating of ballast tanks double-skin void. For bulk carriers, these must be examined annually on certain conditions. Third, amendments on the definition of oil tankers provide further clarification of the ESP Code. These amendments came into force on 1 July 2024.

Resolution MSC.525(106) is a very lengthy resolution. The author will be dividing the write-up as follows, so as to make the material easier to digest:

[1] Annex A, Part A (Part 1 of 4) - An overview of this will be in this article, ie IMSML Website Article 6/2023;

[2] Annex A, Part B (Part 2 of 4) - IMSML Website Article 7/2023, on Monday, 21 August 2023;

[3] Annex B, Part A (Part 3 of 4) - IMSML Website Article 8/2023, on Wednesday, 23 August 2023;

[4] Annex B, Part B (Part 4 of 4) - IMSML Website Article 9/2023, on Friday, 25 August 2023.

Annex A, Part A (Part 1 of 4)

Annex A concerns the Code on the Enhanced Programme of Inspections During the Survey of Bulk Carriers. There are two parts to Annex A:

[1] Part A - Code on the enhanced programme inspection during surveys of bulk carriers having single-side skin construction; and

[2] Part B - Code on the enhanced programme of inspections during surveys of bulk carriers having double-side skin construction.

The focus of this article, the first of four segments, is Annex A, Part A.

Paragraph 2, Renewal Survey - Paragraph 2.3 - Space Protection

The first amendment is a new Paragraph 2.3.1. Paragraph 2 deals with ‘Renewal Survey’, and Paragraph 2.3 is titled ‘Space Protection’. These are the important details of Paragraph 2.3.1:

[1] Where provided, it is mandatory to examine the condition of the corrosion prevention system of ballast tanks;

[2] The following situations (excluding double bottom tanks) require examination at annual intervals:

(a) ballast tanks where the hard protective coating is found to be in less than ‘good’ condition (as defined in Paragraph 1.2.1.11), and it is not renewed; OR

(b) where soft or semi-hard coating has been applied; OR

[3] The following situations for double bottom tanks require examination at annual intervals:

(a) double bottom ballast tanks where the hard protective coating is found to be in less than ‘good’ condition (as defined in Paragraph 1.2.1.11), and it is not renewed; OR

(b) where soft or semi-hard coating has been applied; OR

[4] Thickness measurements shall be carried out as deemed necessary by the surveyor in either [2] or [3] above.

Paragraph 4, Intermediate Survey - Paragraph 4.2 - Single-side Skin Bulk Carriers 5 to 10 years of age

Details to take note of in a new Paragraph 4.2.1.2, ie examination shall be extended to ballast tanks of the same type where the following is found:

[1] A hard coating is found o be in less than ‘good condition’; OR

[2] Corrosion or other defects are found in water ballast tanks; OR

[3] Hard protective coating was not applied from the time of construction.

Details to take note of in a new Paragraph 4.2.1.3, ie for ballast tanks other than double-bottom tanks have to be examined and thickness measurements carried out as necessary at annual intervals where:

[1] A hard protective coating is found to be in less than ‘good’ condition and it is not renewed;

[2] A semi-hard coating has been applied; OR

[3] A hard protective coating was not applied from the time of construction.

Note: Paragraph 4.2.1.3 also clarifies that where a breakdown of hard protective coating is found, the tank in question may be examined when necessary by a surveyor. Plus where corrosion is extensive, thickness measurements shall be carried out.

Annex 7 - Condition Evaluation Report (Executive Summary Report)

For contents of condition in the evaluation report, a new Part 8 - Memoranda, introduced by Paragraph 3, now has to state the following:

[1] Acceptable defects;

[2] Any point s of attention for future surveys, eg for suspect areas;

[3] Where there is a coating breakdown, annual surveys where examination of ballast tanks are to take place.

There is also a new Paragraph 4 for tank/hold corrosion prevention system:

If coating condition of ballast tanks is less than ‘good’, tanks shall be examined at annual surveys.

Annex 9 - Guidelines for Technical Assessment in Conjunction with the Planning of Enhanced Surveys for Single-Sided Skin Bulk Carriers - Renewal Survey Hull

Annex 9 introduces a new updated reference standard for the assessment, ie IACS Recommendation 76, Guidelines for Surveys, Assessment and Repair of Hull Structure - Bulk Carrier, 2007.

Thank you for reading IMSML Website Article 6/2023

Stay tuned for the next IMSML Website Article 7/2023: Resolution MSC.526(106) - Amendments to the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code), Part 2 of 4, Annex A, Part B

Signing-off for today,

Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT

Professor of Maritime and Transport Law

Head of the Centre for Advocacy and Dispute Resolution

Faculty of Law

Universiti Teknologi MARA Shah Alam

Selangor, Malaysia

Friday, 18 August 2023

Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my